Privacy Notice


This Privacy Notice describes the privacy practices of Iberdrola Solutions, LLC ("Iberdrola Texas", "our", "we", or "us") applicable to the information of our individual customers and applicants for services.

This Privacy Notice describes, among other items, the type of personal information that we collect and how we will use and protect your personal information. We are committed to complying with applicable laws and regulations relating to the processing of personal data and to privacy.

We publish the current version of our Privacy Notice on our website and we will update this Privacy Notice from time to time.
This Privacy Notice is subject to change, and Iberdrola reserves, in its sole discretion, the right to revise this Privacy Notice at any time. In the event of any change, the updates to this Privacy Notice will be posted on our website and we will notify you as part of our communications with you.

This Privacy Notice is effective as of Nov 18, 2019.

Who are we?


Your information will be held by Iberdrola Texas. More information on Iberdrola Texas can be found here

Contact information


If you have a question on this Privacy Notice or how we use your personal information, please email dataprotection@iberdrolatexas.com or write to us at Customer Services, Iberdrola Texas, 10343 Sam Houston Park Dr, Suite 230, Houston, TX 77064.

What is Personal information?


Personal information can cover a wide range of areas, but in general, it includes: information you tell us about you and your preferences; information provided by your connected devices such as mobile phones; information we learn from your custom; information we learn about you from our agents, contractors and industry; and information we obtain about you from public sources - please see section Data from third parties.

Personal information can include things that can allow someone to identify you either directly, through your name or customer number, or indirectly, through your address, phone number, date of birth, bank details or email address.

Personal information can also include other things such as your electricity consumption patterns, and locational data from mobile phones and wireless devices to:

Where we collect your Personal information from?


In order to provide you with our energy services, we need to collect and use your personal information. Iberdrola Texas collects your personal information from a number of different sources, including:

Data you give to us:
- When you apply for our products and services;
- When you talk to us on the phone;
- When you use our websites, mobile device apps, or web chat services;
- In emails and letters;
- In customer surveys; and
- If you take part in our competitions or promotions.

Data we collect when you use our services. This includes the amount, frequency, type, location, sales route and recipent information for users of our services:
- Online profile and usage data. This includes the profile you create with us to identify yourself when you connect to our internet, mobile and telephone services, e.g. through our mobile app. It also includes other data about how you use those services.

Data from third parties:
- Electric Reliability Council of Texas ("ERCOT") transmission / distribution service providers ("TDSP’s");
- Federal and State authorities;
- Law enforcement agencies;
- Comparison websites;
- Companies that introduce you to us;
- Loyalty scheme operators;
- Market researchers; and
- Agents and contractors working on our behalf.

Who we share your personal information with


In order to provide our energy services to you, Iberdrola Texas may share your personal information with other entities of the group of companies headed by Iberdrola, S.A. ("Iberdrola Group") and agents, vendors, partners and contractors working on Iberdrola Texas’ behalf or that assist us in operating our business. This includes, without limitation, agents, vendors, partners and contractors in the following categories:

- Customer Service;
- Debt collection companies;
- Customer Research;
- Legal firms;
- Print and Design;
- Technology and IT;
- Digital and social media;
- Data analytics;
- ESB Networks;
- Sales and Marketing; and
- Payment processing.

We may also share personal information we collect about you with companies that assist us with marketing activities or with which we have joint marketing agreements. Joint marketing agreements with other companies allow us to bring information to you about products and services that are different from those we provide. We will not sell or exchange personal information about you with outside marketers or other companies to allow them to independently solicit you for their products or services without giving you the opportunity to decline to have your personal information provided to such outside marketers.
We require our service providers and those with which we jointly market products or services to adhere to confidentiality standards governing the privacy of your personal information. These companies may use and disclose the information we provide to them only for the purposes for which it is provided or as otherwise permitted by law.
We may also need to provide your personal information to other organizations external to Iberdrola Texas or its affiliates, agents, vendors, partners and contractors in connection with the provision of our energy services and to provide you with the products and services you have chosen:

- Consumer reporting agencies;
- Energy assistance agencies;
- Local, state and federal agencies;
- Regulators;
- People whom you have authorized us to share your personal information;
- Other Retail Electric Providers;
- ERCOT TDSPs; and
- To other third parties to the extent we reasonably believe it complies with any legal or regulatory requirements.

We may need to share your personal information with other organizations to provide you with the products or services you have chosen, including:

- If you have a debit, credit or charge card that you use with us we will share transaction details with companies which help us to provide this service (such as Visa and Mastercard); and
- If you make an insurance claim, information you give to us or the insurer may be put on a register of claims. This will be shared with other insurers.

We may share personal information, if we reasonably believe we are required to do so by law, regulation or government authority, to comply with any court order, or legal process, including to respond to any government or regulatory request, to protect the rights and property of us or the public, or to enforce our Terms of Use for use of our website, social media and the Digital Community or other legal rights. We may also cooperate with law enforcement and regulatory agencies in any official investigation and we may disclose information to the relevant agency in doing so.
We may share personal information in connection with any corporate transaction, including, without limitation, any merger, consolidation, restructuring, the sale of stock and/or assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding or other corporate change or financing transaction, including, during the course of any due diligence process or otherwise.

Notwithstanding anything else in this Privacy Notice, we may use, share and disclose aggregate and statistical information (i.e., non-personal information), and information that does not identify a specific individual, for any lawful purpose, without restriction.

How we use your personal information


Here is a list of the ways that we may use your personal information:

- To deliver our products and services to you;
- To bill you for the services you use;
- To resolve your complaints;
- To provide you with information required to ensure you are informed of our product and services;
- To provide you with improved customer service;
- To provide you with useful information on your online account;
- To study how you use our products to help develop our marketing activities and improve our customer service;
- To fulfill our obligations to you;
- To fulfill our obligations to our regulators;
- To assess if you have particular needs or health requirements;
- To provide you with details of State energy initiatives;
- To run our business in an efficient manner;
- To minimize the risk to your account;
- To identify the theft of gas and/or electricity from your premises;
- To detect, investigate, report and seek to prevent financial crime;
- To recover money that is owed to us;
- By providing it to your TDSP so that you can be prioritized for re-connection should there be a power cut or if you have a health condition that we know about;
- To market products and services to you;
- To test new products and services;
- To assess if you have particular needs or health requirements and hold and share this data; and
- To obtain certain energy consumption details from you.

We may also use your personal information based on our legitimate interests. A legitimate interest is when we have a business or commercial reason to use your information (for instance to add value to our services or to improve our customer service). In these cases, we will work to ensure that the collection and processing of your personal information:

- is minimized with regards to the amount of data collected and the extent of any processing;
- will not be overly intrusive to you; and
- will be proportionate in order to meet our legitimate interests, as described below.

Our legitimate interests include:

- Predict and develop what products and services will suit you and the pricing of those products;
- Analyze our interactions with you to improve our customer services for you;
- Display products and services that are suitable for your circumstances when you visit your online account;
- Assess your use of our connected premises products;
- Use your personal data to replicate real circumstances when testing computer systems;
- Seek your consent when it’s needed;
- Analyze your payment patterns and account activity (online and offline) to build a picture of your use of our services and products;
- Utilize existing methods and develop new techniques for identifying financial crime;
- Share your health data with your TDSP for the sole purpose of ensuring your wellbeing is prioritized during a power cut;
- Market products and services to you;
- Alert you to important information about our products and to help you manage your energy account more effectively;
- Develop our products and our service to better meet customer needs; and
- Understand how you use our products and what products may suit you.

Using your information to make automated decisions


Many of our processes are automated to speed up our customer service and make our products and features more relevant to you, such as those automated processes described below:

Improving our customer services to you
We may carry out statistical analysis across our phone, online and mobile communications with you, to better understand how we can make things easier for customers, for example, by finding out how and when it suits you to interact with us.We may also categorize your personal information so that when you call us or visit our online website or mobile app we can predict your most likely next request to improve our customer service to you. For example, if you have e-mailed a complaint to us then subsequently call us, we may use the data we hold to direct you to the most likely appropriate team.

Tailoring products for you
We may consider all aspects of the personal information we hold about you, such as your demographic, product history, location, financial status, how frequently you change products, your preferred communication status, your age, your marital status, your premises type, the lifestyle and occupation details we hold about you, and your prior consumption patterns. We do this so we can predict what products and services will suit you, and so that we can offer you opportunities to act on these insights. We may use this analysis to offer you personalized price quotations.

Online and connected premises products
When you visit your online account we may utilize your preferences and our analysis of you to provide you with products and services that are suitable for your circumstances. To do this we will utilize your log-in information, ‘cookies’ on your computer, and the current products you take from us, to provide you with products and services that may be of interest to you. We will also assess your use of our connected premises products and services, such as  Advanced Metering System ("AMS") energy meters, to allow us to assess and predict your anticipated future energy demand.

Minimizing risk to your account
We may use your personal information to undertake analysis of your payment patterns and account activity (online and offline) to build a picture of your use of our services and products. Where we detect unusual payment activity we may put a hold on your account with us to allow us to investigate. This hold will not impact our delivery of energy to your premises. However, we may conduct further investigations as to the nature of the payment activity and seek additional clarifications from you to ensure any transactions are legitimate. Where we detect fraud, we may report this to appropriate authorities.

Fraud prevention and energy theft


We may need to confirm your identity before we provide products or services to you or your business. Once you have become a customer of ours, we will also share your personal information as needed to help detect fraud and money-laundering risks.
To help identify theft of gas and/or electricity from your property, we will share details of your account, which may include information about alleged criminal offenses, with ERCOT TDSP’s, the police, and/or other law enforcement bodies.

Sending data outside of the USA (by us)


Some of the third parties with whom we may share your personal information in accordance with this Privacy Notice may be located outside of the USA. For example, this could happen if any of our servers that store your personal information are located in a country outside of the USA, or when one of our vendors is located in a country outside of the USA.

If you choose not to give personal information


We may need to collect personal information by law, or under the terms of a contract we have with you. If you choose not to give us your personal information, it may delay or prevent us from providing products or services to your or otherwise meeting obligations, including maintaining your account. It could mean that we will have to cancel a product or service you have with us.

Our communications with you


We believe it is important for Iberdrola Texas, as a responsible energy supplier, to communicate with you to let you know of products, services, and other important information in relation to your energy supply and associated energy services. Communication with you allows us to understand your needs, so we can offer you the right products and services to help and support your personal circumstances. We may also have regulatory or contractual reasons for sending you communications.
Where you call us to inquire about a new product, or you visit our website (or mobile app) to assess different products but do not complete a sale, then we will record your interactions with us. We will use this information to prioritize our communications with you and, where we are permitted to do so, we may contact you to offer you the opportunity to assess whether other products are more suitable for you.
We will always need to send you information on the products and services that you use. However, you can ask us to stop sending you marketing messages by contacting us at any time:

- Visit the Your Preferences section of your online account to change your consent preferences at any time.
- By emailing us at dataprotection@iberdrolatexas.com
- By writing to us at Customer Services, Iberdrola Texas, 10343 Sam Houston Park Dr, Suite 230, Houston, TX 77064.

How long we keep your personal information


We will keep your personal information for as long as you are a customer of Iberdrola Texas.
After you stop being a customer, unless we explain otherwise to you, we’ll hold your personal information based on the following criteria:

- For as long as we have reasonable business needs, such as managing our relationship with you, managing our operations, and equipping us to respond to any questions or complaints you may have;
- In order to contact you for direct marketing purposes where we have a legal basis for doing so;
- For as long as we provide goods and/or services to you and then for as long as someone could bring a claim against us; and/or
- Retention periods in line with legal and regulatory requirements or guidance.

Appropriate safeguards will be implemented to protect your data, including where technical limitations restrict our ability to remove your personal information from our systems.

Disposal of your personal information


Disposal of your personal information will be made in a manner intended to protect the privacy of such information and in accordance with our internal procedures and applicable law.

Security of your personal information


We have implemented technical and organizational measures to protect your personal data from accidental loss and from unauthorized or unlawful modification, access, use or disclosure.

Despite the diligent implementation of such measures, security measures are never completely secure. We are not responsible for the actions of third parties who, despite our security measures, access your personal information.

Obtaining your personal information


You may obtain a copy of the personal information we hold about you:

Through your online account
Find details of the personal data we hold about you online including, the mailing and service address that we hold, historic bills and energy usage, and your contact preferences.

By emailing us
dataprotection@iberdrolatexas.com (subject heading: Subject Access Request- Your Name, Your Account Number)

By writing to us
Data Protection Team, Iberdrola Texas, 10343 Sam Houston Park Dr, Suite 230, Houston, TX 77064.

If you believe that any of the personal information that we have from you is wrong or incomplete, you can contact us.

Cookies and online security


What is a cookie?
A cookie is a small text file which is placed onto your computer (or other electronic device) when you use our website. Cookies can be used to identify that you have visited our website before. Cookies make it easy for websites to collect user specific information about their visitors.

Why do we use cookies?
Iberdrola Texas uses cookies to understand how our website is used and to help enhance the user experience. You can choose not to accept cookies and you can delete any cookies already stored on your computer. Please refer to your file management software and your internet browser’s “Help” menu for further details. However, some of our website functionality may not work fully as a result. Please visit our Cookies page at iberdrolatexas.com/cookies for more information.

What cookies do we use?
Iberdrola Texas may use different cookies when you visit our website. We use cookies to deliver many of the functions on our website and our mobile app that make your browser experience more user friendly. We use five kinds of cookies on our website:

- Strictly necessary cookies;
- Performance cookies;
- Functionality cookies;
- Targeting & advertising cookies: and
- Third party cookies

Our website needs some cookies to be enabled in order for our website to function properly. Other cookies such as targeting and advertising cookies can be disabled without losing the main functionality of our website.
If you use our website without changing your settings, we will assume that you consent to receive all cookies on the Iberdrola Texas website.
For more information on the cookies used on our website, please visit iberdrolatexas.com/cookies

Our website, social media and the Digital Community


The Terms & conditions for use of our website, social media and the Digital Community can be viewed at iberdrolatexas.com

Children’s Online Privacy


Our website is not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If you are under the age of 13, please do not provide any personal information to us. If we become aware that we have collected personal information from a child under the age of 13, we will make commercially reasonable efforts to delete such information from our database.

Third Party Services


Some third-party services we use, such as Google Analytics, may place their own cookies on your computer or mobile devices. Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the data collected to track and examine the use of the website, to prepare reports on the use of website, and share information gathered with other Google services. Google may use the data collected to contextualize and personalize the ads of its own advertising network. Please see http://www.google.com/policies/privacy/partners/ (or any other URL Google may provide from time to time) for information about how Google may use your information and how you may be able to control the information sent to Google. This Privacy Notice covers only our use of cookies, web beacons, and other similar technology, and not the use of such technology by third parties.

Third Party Websites


Our Site may link to third party sites. We do not control and are not responsible for the privacy policies and practices of third parties. As a result, we recommend that you carefully review any applicable third party privacy practices because they may differ from our own. Any link to a third party website does not constitute an endorsement by Iberdrola Texas.